Case Summary (G.R. No. 207373)
Antecedents of the Case
An information was filed against Cheng in November 2000, accusing her of defrauding multiple complainants by failing to return their monetary contributions after she mismanaged the funds. Cheng contended that she did not owe the private complainants any money after 1998, as problems arose from borrowers' defaults in repaying loans, which she claimed depleted the paluwagan's available funds.
Ruling of the Regional Trial Court (RTC)
On February 9, 2007, the RTC convicted Cheng of Estafa, asserting that she misappropriated the money held in trust and failed to return it upon demand despite being aware of her obligation. Cheng received a sentence of 8 years and 1 day up to 20 years of reclusion temporal, mandated to indemnify the private complainants respective amounts.
Ruling of the Court of Appeals (CA)
The CA upheld the RTC's decision on May 31, 2012, confirming the existence of all elements of Estafa, especially noting that Cheng had failed to return the funds despite demands. Although the prosecution did not definitively prove that she was not authorized to lend money to non-members, the CA deemed her failure to account for the funds as circumstantial evidence of misappropriation.
Key Issues
The primary issue on appeal was whether petitioner Cheng was guilty of Estafa beyond a reasonable doubt. Cheng maintained that there was no appropriation involved, as the private complainants were aware that their contributions would be lent to other individuals. Cheng also argued that her inability to return the contributions was due to factors beyond her control, notably the failure of borrowers to repay their loans.
Court’s Findings
The Supreme Court found substantial merit in Cheng’s arguments, emphasizing the legal presumption of innocence and the prosecution's burden to prove guilt beyond a reasonable doubt. The Court ruled that the prosecution did not establish the crucial element of misappropriation, noting that all contributions made by the complainants were executed under the voluntary understanding that the funds would be lent out with thei
...continue readingCase Syllabus (G.R. No. 207373)
Overview of the Case
- This case revolves around a Petition for Review on Certiorari filed by Lourdes Cheng, seeking the reversal of the Decision dated May 31, 2012, and Resolution dated May 6, 2013, from the Court of Appeals (CA).
- The CA affirmed the Regional Trial Court (RTC) of Quezon City’s ruling that convicted Cheng of Estafa under Article 315, paragraph 1(b) of the Revised Penal Code (RPC).
Antecedents of the Case
- On November 24, 2000, an Information was filed against Cheng for Estafa, alleging that from 1994 to 1998, she defrauded numerous individuals by misappropriating funds entrusted to her.
- Cheng was an employee of the National Police Commission (NAPOLCOM) and served as the secretary, treasurer, and administrator of the "NAPOLCOM Employees Paluwagan," where members contributed money to grant loans with a promised interest.
- While initially returning contributions with interest, Cheng failed to do so for the year 1998, leading to complaints from the private complainants.
Details of the Allegations
- The total amount involved in the alleged fraud was Php 838,000.00, which was to be refunded upon demand.
- Cheng claimed financial difficulties in collecting loans from borrowers, which impeded her ability to return contributions.
- A demand letter was sent in July 1999, but Cheng did not comply, prompting the private complainants to file a complaint against her.
Ruling of the Regional Trial Court (RTC)
- On February 9, 2007, the RTC fou